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However, "merely because the method of accounting a taxpayer
employs is in accordance with generally accepted accounting
procedures, this 'is not to hold that for income tax purposes it
so clearly reflects income as to be binding on the Treasury.'"
Commissioner v. Idaho Power Co., 418 U.S. 1, 15 (1974) (quoting
American Automobile Association v. United States, 367 U.S. 687,
693 (1961)). Financial accounting and income tax accounting
methods have different objectives. Thor Power Tool Co. v.
Commissioner, 439 U.S. 522, 542-543 (1979). As stated by the
Supreme Court:
The primary goal of financial accounting is to provide
useful information to management, shareholders,
creditors, and others properly interested; the major
responsibility of the accountant is to protect these
parties from being misled. The primary goal of the
income tax system, in contrast, is the equitable
collection of revenue; the major responsibility of the
Internal Revenue Service is to protect the public fisc.
* * * Given this diversity, even contrariety, of
objectives, any presumptive equivalency between tax and
financial accounting would be unacceptable.
Id.. Nevertheless, "where a taxpayer's generally accepted method
of accounting is made compulsory by the regulatory agency and
that method clearly reflects income, it is almost presumptively
controlling of federal income tax consequences." Commissioner v.
Idaho Power Co., supra at 15 (fn. ref. omitted).
If the taxpayer's method of accounting does not clearly
reflect income, the computation of taxable income shall be made
under such method as, in the opinion of the Secretary, does
clearly reflect income. Sec. 446(b). Respondent has broad
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